Insider Threat and Security Clearance Reform...Improve Risk Management with Appropriate Position...

Insider Threat and Security Clearance Reform

Goal leaders: Beth Cobert, Deputy Director for Management, OMB;

James Clapper, Director of National Intelligence; Katherine Archuleta, Director, Office of Personnel Management; Michael Daniel, Special

Assistant to the President and Cybersecurity Coordinator

FY2014 Quarter 4

Cross Agency Priority Goal Quarterly Progress Update

1

Overview

2

Goal Statement Mitigate the inherent risks and vulnerabilities posed by personnel with trusted access to government information, facilities, systems and other personnel

Urgency A series of vetting program failures, followed immediately by Presidentially directed reviews, identified solutions needed to safeguard our personnel and protect our nation’s most sensitive information.

Vision The Federal Government will mitigate the inherent risks posed by personnel with access to government information, facilities, systems and other personnel. To achieve this objective, agencies will work with the Performance Accountability Council (PAC) and the Senior Information Sharing and Safeguarding Steering Committee (SISSSC) to:

o Improve Enterprise Management of Information Technology and Resources

o Develop Insider Threat Programs

o Implement Continuous Evaluation

o Improve Availability and Sharing of Relevant Information

o Implement Federal Investigative Standards (FIS)

o Improve Oversight and Quality of Background Investigations (BI) and Adjudications

o Improve Risk Management with Appropriate Position Designations and Associated Investigations

o Improve Security and Suitability Alignment and Reciprocity

Quarterly Progress Update

3

Strong Foundation

• Program Management Office (PMO) established and fully staffed

• Governance identified, strong PAC leadership engagement

• Leveraging on-going Agencies’ security and suitability Reform efforts

• Multiple interagency working groups established, work well underway

Aligned Vision

• Overlapping Enterprise Management efforts (directed by the National Defense Authorization Act (NDAA) and the White House review) have been aligned for synergy and efficiency. Updates are reflected in the key milestone under “Improve Enterprise Management of Information Technology and Resources.”

Overall Risks and Challenges

• Harmonizing government-wide efforts across divergent cultures

• Integrating similar Agency-centric projects at varying stages of development

• Developing new or updating existing Information Technology (IT) capabilities to achieve Reform goals

• Overlapping authorities may impact enterprise solutions

• Legislation competing with Administration plans and policies

• Sustaining sufficient resources and leadership focus beyond current crises

Progress Update Q4

4

Sub-Goal

Improve Enterprise

Management of Information

Technology and Resources

Develop Insider Threat

Programs

Implement Continuous Evaluation

Improve Availability

and Sharing of Relevant

Information

Implement Federal

Investigative Standards

Improve Oversight and Quality of

Background Investigations and

Adjudications

Improve Risk Management

with Appropriate Position

Designations and Associated

Investigations

Improve Security and Suitability Alignment and

Reciprocity

Qu

arte

rly

Pro

gres

s (Q

4)

Key

Mile

sto

nes

Acc

om

plis

hed

•Drafted Trusted Workforce Strategy

•Drafted IT Reform Strategy

•Communicated Phase 1 CAPE Study to Congress

•Initiated Phase 2 CAPE study proposal (in progress)

•Conducted benchmarking

•Established Risk-based prioritization of reinvestigations

•Defined Initial Operating Capability (IOC) and Full Operating Capability (FOC)

•Partially achieved Program establishment criteria

•Approved Privacy Act compliance documents for Continuous Evaluation (CE)

•Identified near term bridge to CE solutions

•Reached DHS and DOJ agreement on appropriate Federal funding

•Established Mental Health Working Group

•Implemented Tier 1 IOC

•Implemented Tier 2 IOC

•Developed plans for accelerating specifically identified records checks

•Agency reporting to PAC on progress initiated

•Developed requirements for Tool for Investigative Quality

•Negotiated DoD and OPM plan for standardized approach to addressing third party influence to application /questionnaire

•Initiated assessment of federal and contract background investigator workforce initiated

•“Access Score” study underway

•Position Designation tool requirements working group underway

•Established specific timing and work plans for credentialing criteria established

•Developed draft guidance on credentialing criteria and suspension mechanisms developed

•Updated National Security Reciprocity Policy in progress

Action Plan Summary

5

Impact Area / Sub-Goal Major Actions to Achieve Impact Key Indicators

Improve Enterprise Management of Information Technology and Resources: Increase enterprise management and oversight and make greater use of automation to access information relevant to background investigations and adjudications.

• Recompose the PAC to actively manage and oversee enterprise issues

• Develop and execute Enterprise Reform IT strategy to ensure interoperability, operationalize CE, automate suitability processes, and improve sharing of relevant information

• Establish Enterprise Line of Business (LOB) mechanisms to collect, analyze, manage, oversee government-wide spending linked to enterprise information technology and workforce development

• Number of agencies investing in enterprise line of business

• Percentage of IT Strategy implemented

• Percentage of Increase/Decrease of Annual Suitability/Security Program Costs by Agencies

Develop Insider Threat Programs: Establish an insider threat program that complies with the President’s National Insider Threat Policy and Minimum Standards in each department or agency that handles classified information.

• Achieve program establishment • Achieve Initial Operating Capability (IOC)

• Achieve Full Operating Capability (FOC)

Note: As defined and promulgated by the National Insider Threat Task Force (NITTF) and Steering Committee.

• Percentage of Department or Agencies (D/As) that have met the three program establishment criteria

• Percentage of agencies that have met the IOC/FOC criteria

Implement Continuous Evaluation: Accelerate the implementation of a standardized program of Continuous Evaluation (CE), ensure full integration with agency Insider Threat Programs, and reassess Periodic Reinvestigation intervals as appropriate.

• Accelerate government wide implementation of a standardized program of CE, ensure full integration with agency Insider Threat Programs, and reassess Periodic Reinvestigation (PR) intervals as appropriate

• Percentage of designated D/As meeting IOC

• Percentage of designated D/As meeting FOC

• Percentage of overdue PR population screened using automated record checks

Action Plan Summary

6


Improve Availability and Sharing of Relevant Information: Ensure internal and external processes exist for reporting and sharing information.

• Improve access to and availability of State and Local criminal records

• Clarify and expand requirements for reporting actions and behavior of employees and contractors to support decisions on access to facilities, classified/sensitive information, and IT systems

• Percentage of local law enforcement records provided of total number requested

• Percentage of local law enforcement records provided via automated means

Implement Federal Investigative Standards: Accelerate implementation of elements of Revised Federal Investigative Standards (FIS) to address gaps identified in existing investigative processes.

• Accelerate implementation of elements of Revised FIS to address gaps identified in existing investigative processes

• Percentage of agencies in compliance with Tiers 1 & 2 IOC

• Percentage of agencies in compliance with Tier 3 IOC

• Percentage of agencies in compliance with Tiers 4 & 5 IOC

• Percentage of agencies in compliance with FOC

Improve Oversight and Quality of Background Investigations and Adjudications: Improve oversight to ensure investigations and adjudication meet government-wide quality standards.

• Accelerate the development of quality standards and implementation of consistent measures and metrics for investigations and adjudications

• Improve the quality of existing oversight mechanisms for Federal and contract investigators, and Federal adjudicators

• Improve detection of and response to applicant falsification in current processes

• Percentage of agencies using Investigative Quality Standards

• Ratio of Quality to Non-Quality completed investigations

• Percentage of targeted agencies assessed for oversight purposes

Action Plan Summary

7


Improve Risk Management with Appropriate Position Designations and Associated Investigations: Drive adherence to existing security and suitability position designation, reinvestigation timeliness guidelines, prioritizing submissions based on risk, and increasing the frequency of reinvestigations for high risk populations.

• Reduce reinvestigation backlog using a risk-based

approach

• Reduce total population of 5.1M Secret and TS/SCI clearance holders to minimize risk of access to sensitive information and reduce cost

• Percent reduction in overdue reinvestigations

• Percent reduction in total number of clearance holders

Improve Security and Suitability Alignment and Reciprocity: Ensure alignment through consistent standards, training and processes, avoiding redundancy and duplicative systems and effort, and improving reciprocity.

• Establish new Government-wide adjudication requirements for credentials issued to include the currently optional OPM supplementary standards

• Revise the Final Credentialing Standards to establish a suspension mechanism

• Accelerate implementation of National Security and Suitability Investigator and Adjudicator Training Standards to drive consistency and improve reciprocity

• Number of agencies fully implementing government-wide credential standards/criteria

• Percent of agencies in compliance with Training Standards (with measurements beginning one year from standards signature date)

Governance and Contributing Programs (PAC)

Office of Personnel Management (OPM)

Suitability Executive Agent

Contributing OPM Programs: FIS/ES/OGC

Authorities: EO’s 10450, 12968,

13467, 13488; 5 USC Part 731, 732, 736;

HSPD-12

Office of Management and Budget (OMB)

DDM Chair, Performance

Accountability Council (PAC)

Contributing OMB Programs: DM/DB

Authorities: EO 13467

Office of the Director National Intelligence (ODNI)

Security Executive Agent

Contributing ODNI Programs: NCIX/SSD

Authorities: EO’s 10450, 12968, 13467, 13587, 13488;

USC Title 50

PAC Program Management Office (PMO)

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DHS

DoD USDI P&R

DOJ

OMB DM DB

FBI ODNI NCIX SSD

OPM FIS

ES/OGC

Treasury

The Performance Accountability Council* (PAC) is ultimately responsible to the President for driving implementation of the reform effort, ensuring accountability by agencies, ensuring the Security and

Suitability Executive Agents align their respective processes, and sustaining reform momentum.

*Current PAC member agencies: DHS, DoD, DOJ, OMB, FBI, ODNI, OPM, Treasury, DOE, ISOO, NSC, GSA

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Governance (SISSSC)

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The Senior Information Sharing and Safeguarding Steering Committee (SISSSC) is ultimately responsible to the President for ensuring senior-level accountability for the coordinated interagency development

and implementation of policies and standards regarding the sharing and safeguarding of classified information on computer networks.

Executive Agent for Safeguarding

SecDef & NSA Jointly

National Insider Threat Task Force

Co-Chaired by AG (FBI) & DNI (NCIX)

Classified Information Sharing & Safeguarding

Office Executive Secretariat within

ODNI/PM-ISE

SISSSC Co-Chaired by National Security Council staff

Office of Management and Budget












Governance (CAP Goal)

10

CAP Goal Leaders: Beth Cobert, OMB DDM; Michael Daniel, NSC Cyber; James Clapper, DNI; Katherine Archuleta, D/OPM

Performance Accountability Council (PAC), Executive Agents (DNI, OPM), PAC PMO (DoD, OPM, ODNI, DOJ, DHS, OMB, Treasury, FBI), OMB

OPPM, OMB eGov, NSC Cyber

FIS Senior Lead: • Katherine

Archuleta, SuitEA

• James Clapper, SecEA

BI Oversight & Quality Senior Lead: • Katherine

Archuleta, SuitEA


Mitigating Decision Criteria Gaps Senior Lead: • Katherine

Archuleta, SuitEA


Governance – The Performance Accountability Council’s Program Management Office, comprised of representatives from the Office of Management and Budget, Office of the Director of National Intelligence, Office of Personnel Management, Department of Defense, Department of Homeland Security, Department of Treasury, Department of Justice, the Federal Bureau of Investigation, as well as the Senior Information Sharing and Safeguarding Steering Committee, will be responsible for driving government-wide implementation of these goals, and identify recommended solutions to further safeguard our personnel and protect our nation’s most sensitive information.

Insider Threat Matters

Senior Lead: • Michael

Daniel, NSC, SISSSC Co-Chair

CE Implementation

Senior Lead: • James Clapper

Sec EA

Enterprise Management

Senior Lead: • Beth Cobert,

DDM OMB, PAC Chair

Information Sharing

Senior Lead: • Katherine

Archuleta, SuitEA


PR Backlog / Position Designation

Senior Lead: • Katherine Archuleta,

SuitEA • James Clapper,

SecEA

Oversight & PM SISSSC, NSC Cyber, OMB E-Gov, NITTF

Work Plan: Improve Enterprise Management of Information Technology and Resources

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Alignment Goals: • Improve enterprise operations

Major Actions: • Recompose the PAC to actively manage and oversee enterprise issues • Develop and execute enterprise Reform IT strategy to ensure interoperability, operationalize CE, automate suitability processes, and

improve sharing of relevant information • Establish mechanisms to manage and oversee government-wide spending for suitability and security processes

Milestone Summary

Key Milestones Milestone Due Date

Milestone Status

Owner

The PAC will immediately identify new members and meet as reconstituted within 30 days of this report.

4/2014 Complete PAC

The PAC Chair (OMB/DDM) will convene members at least quarterly, and hold senior leaders accountable for implementation as well as bring in agencies whose capabilities are critical to success (e.g., DOJ, FBI, DHS, State, Treasury).

5/2014 Complete PAC

The PAC will immediately establish a PMO to provide full-time effort and expertise on tasks of implementation. PMO membership shall include a minimum of 1 FTE from each of the following: OMB, DoD, ODNI, OPM, DHS, DOJ, and FBI.

4/2014 Complete PAC

The PAC Chair will propose funding for the PMO through the FY15 budget ($500,000 annually per PMO member agency) for implementation efforts continuing at least through FY20 to ensure sustained momentum of these reform efforts.

2/2014 Complete PAC

The PAC Chair will engage the Federal CIO and or OSTP/Chief Technology Officer for support to the assessment of current IT capabilities across this “line of business” and to develop IT strategy inclusive of line of business objectives for long term needs of suitability and security processes.

1/2015 Not Started PAC

The PAC will conduct benchmarking of similar Government screening technologies (DHS, TSA, National Counterterrorism Center), as well as benchmarking of commercial solutions for risk-management and rules-based automation of previously manual workflows.

10/2014 On Track PAC PMO

Work Plan: Improve Enterprise Management of Information Technology and Resources (cont.)

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Milestone Summary

Key Milestones Milestone Due Date Milestone Status Owner

The PAC PMO will lead the joint development of an Enterprise IT strategy for the Security, Suitability, and Credentialing Line of Business (LOB).

12/2014 At Risk* PAC PMO,

ODNI, OPM, DoD

The PAC will establish a mechanism to collect baseline financial data on security and suitability activities. 4/2015 Complete PAC PMO

PAC will build on the conclusions of the NDAA efficiency and quality study to develop specific plans for an ongoing capability to evaluate costs of suitability and security activities; identify opportunities for improvement; and provide agency information on quality and timeliness.


The PAC PMO will lead the joint development of a Trusted Workforce Strategy,

for the Security, Suitability, and Credentialing LOB. 12/2014 At Risk*

PAC PMO, ODNI, OPM,

DoD

PAC will issue enterprise implementation plans to accomplish the Trusted Workforce Strategy and the Enterprise IT strategy.

3/2015 At Risk* PAC PMO

*Working with key stakeholders to finalize strategy development and coordination.


13

Milestone Summary


Taking into account the results of the CAPE analysis and the results of any ongoing reviews of recent unauthorized disclosures of national security information, the SecDef, ODNI, and OMB with the PAC leadership shall jointly develop, implement, and provide to the appropriate committees of Congress a strategy to modernize all aspects of personnel security for the DoD with the objectives of improving quality, providing for continuous monitoring, decreasing unauthorized disclosures of classified information, lowering costs, increasing efficiencies, and enabling and encouraging reciprocity. The strategy will include performance metrics and will align with the forthcoming Trusted Workforce Strategy.

TBD* At Risk DoD/OMB/OD

NI/PAC

*Following CAPE progress reports to Congress this past quarter, the associated NDAA timelines have been extended to permit continued study and analysis. This milestone is dependent on the CAPE study results and due dates will be assigned upon consideration of CAPE study results. Original date of 12/2014 changed to TBD to reflect the dependency.


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Milestone Summary


As mandated by the NDAA, not later than February 2015, (at the same time as the POTUS budget submission to Congress for FY16) and yearly through FY19, the SecDef, ODNI, and OMB with PAC leadership shall jointly submit to Congress a report on the metrics and an assessment using the metrics of the effectiveness of the DoD Modernization Strategy in meeting its objectives.

2/2015 Not Started DoD/ODNI/ OMB/PAC

ODNI shall develop a risk-based approach that prioritizes which cleared individuals shall be subject to frequent reinvestigations and random checks and ensure that if the system of continuous monitoring for all cleared individuals is implemented in phases, it will be implemented on a priority basis and at the level of scrutiny based on level of risk.

10/2014 Complete

ODNI

Modify Security/Suitability forms to account for reform activities such as mental health question, expanded reporting requirements and CE SF 86 - 8/2014 SF85P – 8/2015 SF85 – 8/2015

8/2014 8/2015

Missed*

ODNI/OPM/ OMB PAC

*Missed deadline for SF 86 due to on-going discussions.

Work Plan: Develop Insider Threat Programs

15

Alignment Goals: • E.O. 13587, Steering Committee Priority #2: Establish Insider Threat Programs

Major Actions: • Achieve program establishment • Achieve Initial Operating Capability (IOC), see detailed IOC requirements on next slide • Achieve Final Operating Capability (FOC), see detailed FOC requirements on next slide

*Defined on next slide

Milestone Summary


Achieve establishment criteria* 1/2015 Partially complete NITTF

Achieve IOC* 1/2017 At Risk NITTF

Achieve FOC* TBD TBD NITTF

Work Plan: Develop Insider Threat Programs (cont.)

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Requirements for Insider Threat Programs

Major Action #1: Program Establishment

Basic requirements

Major Action #2: Initial Operating Capability (IOC)

Program establishment plus the following

Major Action #3: Final Operating Capability (FOC)

IOC plus the following

Name a responsible senior official(s) Procedures in place for oversight, reporting, and record retention

Regular (if possible, electronic) access to insider threat-related information from counterintelligence, security, information assurance, HR, law enforcement, etc.

Promulgate an agency head-signed Insider Threat Program policy

Some capability to pull data from appropriate sources to retroactively analyze and respond to anomalies

Tailored triggers to monitor cleared user activity on any agency network accessed (including unclassified), as well as portable devices

Develop an Insider Threat Program implementation plan

User Activity Monitoring on at least one classified network

Access to counterintelligence reporting and adversarial threat information

Employee notification of monitoring (i.e., banner)

A centralized “hub” to proactively assess data

Annual employee awareness training Response capability to follow-up on anomalous activity

Trained Insider Threat Program personnel Conduct self-assessments

Work Plan: Implement Continuous Evaluation

17

Alignment Goals: • Increase availability and quality of critical information to improve decision making • Reduce inherent risk in current processes • Improve enterprise operations

Major Actions: • Accelerate the implementation of a standardized program of Continuous Evaluation (CE), ensure full integration with agency Insider

Threat Programs, and reassess Periodic Reinvestigation intervals as appropriate

Milestone Summary


ODNI will have an initial CE capability for the most sensitive TS and TS/SCI population. 12/2014 At Risk* ODNI

ODNI will implement CE capability for all TS and TS/SCI cleared personnel. 12/2016 On Track ODNI

DoD will expand its CE pilots to include a sample of 100,000 cleared military, DoD civilian, and contractor personnel updated on an ongoing basis from trusted data sources.

10/2014 On Track DoD/ODNI

DoD will expand its CE capability to 225,000 personnel. 12/2015 On Track DoD

DoD will expands CE capability to 500,000 by the end of 2016. 12/2016 On Track DoD

*The ODNI is developing an Executive Branch-wide CE capability that can be scalable to cover the entire cleared population. CE will be rolled out in a phased approach, with a goal to have CE completed on a portion of the Tier 5 population in the Executive Branch by the end of FY16.

Work plan: Implement Continuous Evaluation (cont.)

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Milestone Summary


DoD will expand its CE capability to 1 million during 2017. 12/2017 On Track DoD

Through FY 2015 budget guidance, OMB required DOJ, Treasury, and DHS to identify agency funding to prioritize automation requirements for critical key databases that will be essential to service and enable CE capabilities. 2/2014 Complete PAC PMO

Issue and promulgate CE Policy (SEAD # TBD) 9/2016 Not Started ODNI/OMB

PMO

Publish DoD Continuous Evaluation Concept Demonstration (CECD) SORN

7/2014 Complete DoD/PMO/

OMB

In response to the President’s Review Group, provide a recommendation to the PAC on the use of a continuous monitoring standard for vetting personnel for access to classified information. 9/2017 Not Started

ODNI/PMO/OMB

Work plan: Improve Availability and Sharing of Relevant Information

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Alignment Goals: • Increase availability and quality of critical information to improve decision making

Major Actions: • Improve access to and availability of State and Local criminal records • Clarify and expand requirements for reporting actions and behavior of employees and contractors to support decisions on access to

facilities, classified/sensitive information, and IT systems

Milestone Summary


Milestone Status Owner

Complete the study of specific areas for improving information sharing between the Federal Government and state and local law enforcement agencies through the Records Access Task Force, mandated by the NDAA, and issue report. 4/2014 Complete OMB

Reach agreement with DHS and DOJ on the appropriate Federal funding mechanisms to encourage cooperation or compliance with existing statutes to share data with Federal officials.

7/2014 Complete DHS/DOJ

The PAC and DOJ will develop training and educational materials to help states and localities understand their legal obligations and the importance of data-sharing along with funding available to offset the cost of automation.

10/2014 On Track PAC

PMO/DOJ

The PAC will work with ODNI and OMB to publish the revised Reporting Requirements policy (SEAD 400) for national security positions, and then establish a working group to expand those requirements to other suitability and contractor populations.

7/2014 Missed* PAC PMO

*July date missed. Numerous comments received during the interagency coordination process are now being reviewed.

Work plan: Improve Availability and Sharing of Relevant Information (cont.)

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Milestone Summary


Milestone Status

Owner

The PAC will work with OMB’s Office of Federal Procurement Policy and the Federal Acquisition Regulation Council to propose an appropriate rule to establish needed reporting requirements for the contractor population. TBD* Not Started PAC PMO

In coordination with other Administration efforts, the PAC will establish a working group with participation from ODNI, OPM, DoD, the Department of Veterans Affairs (VA), the Department of Health and Human Services (HHS), and other appropriate Federal experts to further examine the relevant intersection of mental health issues and suitability and security reporting.

10/2014 Complete PAC PMO

Further explore recommendations provided by the NDAA Records Access Task Force regarding amendment, modification or clarification to Title 5 U.S.C. Section 9101.

10/2015 Not Started PAC PMO

Explore feasibility for ISPs to include search of the Department of State, Bureau of Consular Affairs, American Citizen Services (ACS), where an individual has contacted ACS for assistance after they have been arrested abroad.

10/2015 Not Started PAC PMO

Establish a Federal Background Investigations Liaison Office to oversee education initiatives and resolve issues that may develop between Federal investigative service providers and State/local law enforcement agencies

10/2015 On Track OPM

*Dependent on SEAD 400 policy issuance. Due date will be established upon consideration of the final issued Reporting Requirements policy. Original date of 10/2014 changed to TBD to reflect the dependency.

Work plan: Implement Federal Investigative Standards

21

Alignment Goals: • Increase availability and quality of critical information to improve decision making • Reduce inherent risk in current processes • Improve enterprise operations

Major Actions: • Accelerate implementation of elements of Revised Federal Investigative Standards (FIS) to address gaps identified in existing investigative

processes

Milestone Summary


Milestone Status

Owner

Security and Suitability Executive Agents will submit the comprehensive FIS Implementation Plan to the PAC, including detailed timelines and cost estimates where feasible to fill gaps in current practice. 4/2014 Complete OPM/ODNI

The PAC will work with the Executive Agents and agencies to accelerate implementation of the critical checks to enable the acceleration of full implementation across government to 2016. 12/2016 On Track PAC PMO

Issue and promulgate SEAD 5 -Collection, Use, and Retention of Publicly Available Electronic Information (PAEI)

12/2014 At Risk* ODNI/OMB

• Develop a plan to Accelerate the following items: o SSA Check o Defense Management Data Center Check o Scattered Castles o Fully Implement ESI o Expand automated checks to verify citizenship, measure effectiveness of DHS SAVE checks


* The draft PAEI policy is currently being coordinated.

Work plan: Implement Federal Investigative Standards

22

Milestone Summary


Milestone Status

Owner

Achieve IOC for Tier 1 and Tier 2 investigations. 10/2014 On Track OPM

Achieve IOC for Tier 3 investigations.

10/2015 On Track ODNI/ OPM

Achieve IOC to Tier 4 and Tier 5 investigations.


Achieve FOC for all Tier level investigations.


Finalize and issue the Community Handbook detailing the conduct of background investigations based on the FIS requirements and methodologies. 10/2015 On Track

ODNI/ OPM (FISIWG)

Beginning FY 14, Q4 Departments/Agencies will report to the PAC progress on FIS implementation milestones. 9/2014 On Track ODNI/ OPM

Work plan: Improve Oversight and Quality of Background Investigations and Adjudications

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Alignment Goals: • Reduce risks that are inherent in our current processes

Major Actions: • Accelerate the development of quality standards and implementation of consistent measures and metrics for investigations and

adjudications, and improve the quality of existing oversight mechanisms for Federal and contract investigators, and Federal adjudicators • Improve detection of and response to applicant falsification in current processes

Milestone Summary


Milestone Status

Owner

The Executive Agents will issue for PAC approval consistent government-wide quality standards for investigations for the first time and begin collecting quality metrics based on these standards by October 2014.

6/2014 Missed* ODNI/OPM/

DoD (QAWG)

The Quality Assessments Working Group (QAWG) will develop requirements for a quality assessment tool for investigations.

9/2014 Complete ODNI/OPM/

DoD (QAWG)

Once standards are approved and quality assessment tool is created issue implementation guidance for quality standards and tool.

TBD** Not Started ODNI/OPM/

DoD (QAWG)

Ongoing, the PAC and the Security and Suitability Executive Agent will work with agencies to develop adjudicative quality standards, critically examine the existing process, assess the adequacy of oversight mechanisms in place, and share best practices.

10/2015 Not Started ODNI/OPM/

DoD (QAWG)

The PAC will work with DoD and OPM to expand standardized e-QIP for military and contractor personnel to address third party influence/falsification. 10/2014 On Track PAC

*Currently adjudicating comments received on draft quality standards. **Dependent on tool implementation. Original date of 3/2015 changed to TBD to reflect the dependency.

Work plan: Improve Oversight and Quality of Background Investigations and Adjudications (cont.)

Milestone Summary


Milestone Status

Owner

The PAC will develop IT capabilities and other tools to enable detection of falsification that can be integrated with existing systems. 9/2015 Not Started PAC

Develop standard criteria and procedures to ensure agencies respond appropriately to falsification in all types of security clearance, suitability and credentialing adjudications. 10/2015 Not Started ODNI/OPM

Develop and implement improved investigator and adjudicator training to better identify and act upon falsification.

10/2015 Not Started ODNI/OPM/

DoD (TSIWG)

Develop policy and procedures to address problems that occur when third parties are involved in completing suitability and security questionnaires on behalf of applicants (e.g. military recruiters).

10/2015 On Track OPM/DoD

Develop better tools to validate self-reported information against other available independent sources (e.g., social media, credit, or human resources data). 10/2015 Not Started

PAC PMO/OPM

Issue and promulgate SEAD on National Security Adjudicative Guidelines. 10/2015 On Track ODNI/OMB

Work plan: Improve Oversight and Quality of Background Investigations and Adjudications (cont.)

25

Milestone Summary


Milestone Status

Owner

PAC review of, and action on, DoD Report to Congress setting forth a comprehensive analysis comparing (a) the quality, cost, and timeliness (for each type and level of clearance) of security clearance investigations/reinvestigations of DoD employees/contractors that are conducted by OPM with (b) the quality, cost, and timeliness (for each type and level of clearance) of security clearance investigations/reinvestigations that are conducted by DoD components; identifying the elements that contribute to cost, schedule, and performance; identifying mechanisms for permanently improving the transparency of the cost structure of personnel security investigations and reinvestigations; and determining whether the current DoD approach for obtaining personnel security investigations and reinvestigations for DoD employees and contractor personnel is the most efficient and effective approach.

TBD* On Track* DoD

PAC review of and action on Comptroller General Quality Analysis (due May 2014) of the Executive branch personnel security process.

TBD**

Not Started PAC PMO

PAC review of and action on Comptroller General report to Congress (due June 2014) of its Quality Analysis.

TBD**

Not Started PAC PMO

In response to a President’s Review Group recommendation, provide a recommendation to the PAC on whether background investigations/security clearance vetting should be an inherently governmental function, and if not, whether it could be performed by a non-profit, private sector corporation.

10/2014 On Track PAC

*.Following CAPE progress reports to Congress this past quarter, the associated NDAA timelines have been extended to permit continued study and analysis. This milestone is

dependent on the CAPE study results and due dates will be assigned upon consideration of CAPE study results. The original milestone due date was 3/2014. **GAO study is still on-going. Due Date will be established once study is complete. The original milestone due date was 10/2014.

Work plan: Improve Risk Management with Appropriate Position Designations and Associated Investigations

26

Alignment Goals: • Reduce inherent risk in current processes

Major Actions: • Reduce periodic reinvestigation backlog using a risk-based approach • Reduce total population of 5.1M Secret and TS/SCI clearance holders to minimize risk of access to sensitive information and reduce cost

Milestone Summary


Milestone Status

Owner

OMB will distribute to the President’s Management Council (comprised primarily of agency Deputy Secretaries) the results of agencies’ compliance with the DNI’s October 2013 memorandum that directs agencies to use a risk-based approach to identify high risk populations and prioritize reinvestigations that have come due or are overdue.

4/2014 Complete OMB/ ODNI

OMB will distribute to the President’s Management Council, the results of agency compliance with October 2013 guidance from the DNI to review all positions determine whether it continues to require access to classified material.

4/2014 Complete OMB/ ODNI

The Security Executive Agent will determine a near-term government-wide strategy for agencies to identify high risk populations through the use of automated records checks (e.g. derogatory credit or criminal activity) and prioritize overdue investigations based upon risk posed by job responsibilities and access in order to reduce risks posed by potential insider threats.

10/2014 Complete ODNI

Work plan: Improve Risk Management with Appropriate Position Designations and Associated Investigations (cont.)

27

Milestone Summary


Milestone Status

Owner

OPM and ODNI will work with OMB to finalize a joint regulation to refine the designation of national security positions and more accurately align investigations with risks. 8/2014 Missed*

OPM/ODNI/OMB

In response to a President’s Review Group recommendation, provide advice to the PAC on whether there should be additional differentiation for security clearances including “administrative access” clearances for IT personnel.

10/2014 On Track NSC/ODNI

In response to a President’s Review Group recommendation, advise the PAC on whether to develop an “access score” capability to evaluate access to sensitive information; and subject personnel with high access scores to additional monitoring.

10/2014 On Track** ODNI/DoD PAC PMO

Modify existing position designation tool to reflect 5CFR 1400 requirements. 10/2015 On Track ODNI/OPM

Issue joint DNI/OPM implementation guidance for position designations under 5 CFR 1400 and other populations. 10/2015 Not Started ODNI/OPM/

* OPM and ODNI team have reached staff-level agreement on the text of the Final Rule; Federal Register notice currently being drafted. ** Technical capabilities pilot conducted and results provided to the Privileged Access Senior Steering Group

Work plan: Improve Security and Suitability Alignment and Reciprocity

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Alignment Goals: • Reduce risks that are inherent in our current processes

Major Actions: • Establish new Government-wide adjudication requirements for credentials issued to include the currently optional OPM supplementary

standards • Revise the Final Credentialing Standards to establish a suspension mechanism • Promulgate necessary Executive Branch-wide policy to mitigate gaps and inconsistencies in decision criteria

Milestone Summary


Milestone Status

Owner

The PAC will identify the specific timing of actions to mandate supplemental credentialing criteria to apply to all persons with access to government facilities and information systems, including modifications to the FAR. 10/2014 Complete PAC PMO

OPM will issue additional guidance to outline the criteria and procedures for suspension of PIV credentials.

3/2015* On Track OPM

Issue and promulgate updated National Security Reciprocity policy 9/2016 On Track ODNI

*Suspension criteria will be incorporated into supplemental credentialing criteria to be issued in March 2015.

Work plan: Improve Security and Suitability Alignment and Reciprocity

29

Milestone Summary


Milestone Status

Owner

Within 90 days of approval of implementation plan, agency heads must complete a training gap analysis and mitigation plan for each of the disciplines wherein government staff or contractor employees perform investigations or adjudications for their agencies. 10/2014 On Track

OPM/DNI (TSIWG)

Within 180 days of approval of implementation plan, agencies must develop and implement mitigation strategies to close training gaps.

1/2015 On Track OPM/DNI (TSIWG)

Within 270 days of approval of implementation plan, agencies must resolve training gaps identified for incumbent personnel.


Within 365 days of approval of implementation plan, agencies must implement final compliant training programs for all future personnel performing investigations or adjudications.


Key Indicators –Enterprise Management of Information Technology and Resources

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Indicators in development: Number of agencies investing in enterprise line of business, Percentage of Suitability and Security processes that are automated, Percentage of Enterprise IT Strategy implemented, Percentage of Increase/Decrease of Cost by Agencies

High Level Indicator Projected Initial Collection Date Potential Target Areas

Number of agencies investing in enterprise line of business

TBD TBD

Percentage of Suitability and Security processes that are automated

TBD TBD

Percentage of Enterprise IT Strategy implemented

TBD TBD

Percentage of Increase/Decrease of Annual Suitability/Security Programs Cost by Agencies

TBD TBD

Implement Enterprise Management – Timeliness Data (Fastest 90%)

Indicator Source Baseline* Target Frequency Latest Data FY14 (Q4)

Trend

Government-wide Security Clearance Timeliness – Initial Secret Cases

ODNI and all Agencies

In 2005 – 265 Days

Average for Secret & Top

Secret Combined

74 Days End-to-

End

Quarterly 52 Days Consistently Meeting Goal

Government-wide Security Clearance Timeliness – Initial Top Secret Cases

ODNI and all Agencies

114 Days End-to-

End

Quarterly 107 Days Consistently Meeting Goal

*Baseline Timeliness metrics were based on IRTPA collection methodology, which only included investigation and adjudication timeliness, but did not include initiation timeliness

$0

$200,000,000

$400,000,000

$600,000,000

$800,000,000

$1,000,000,000

$1,200,000,000

$1,400,000,000

$1,600,000,000

$1,800,000,000

$2,000,000,000

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 2012

Year

Personnel Security Costs, 1995-2012

NOTE 1: Both DOD and DOJ had significant increases in personnel security costs in FY 2001.

NOTE 2: Intelligence Community personnel security costs not included prior to 2006.

NOTE 3: Spike in FY 2010 total is attributed to DOD – “Personnel Security Investigation costs are now fully consistent with direct DoD tabulations of

funds paid to the Office of Personnel Management for that purpose. Estimates for years FY08 through FY10 averaged around $220 million more than

had been previously estimated. Personnel Security costs were higher than previously reported for FY09 because of the baseline changes, and

between FY09 and FY10 costs increased by around $50 million. Of that, $38 million is from increased payments for security investigations, with the

remainder resulting from increased numbers of civilian 080 security specialists supporting the clearance processing.”

Contextual Indicators – Enterprise Management Resources

31

Note: Costs calculated using current-year (FY13) prices, which have remained fixed since FY10

(SSBI: $4005; SSBI-PR/Phased PR: $2711; BI ($3189); MBI/LBI ($752); NACLC ($228) ANACI ($260); NAC/NACI: $125) 32

Key Indicators – Implement Enterprise Management

Key Indicators – Insider Threat Programs

33

Insider Threat - Key Implementation Data

Indicator Source Public/ Internal

Baseline Target Frequency Latest data Trend

Percentage of agencies1 that have satisfied the program establishment criteria

KISSI2 Internal 0% 100% Quarterly FY14, Q23

Percentage of agencies that have achieved IOC

KISSI Internal 0% 100% Quarterly FY14, Q2

While in progress, the latest projected date for an agency achieving IOC


Percentage of agencies that have achieved FOC


While in progress, the latest projected date for an agency achieving FOC


1 Results reflected as a government-wide average. Individual agency results are weighted by the number of cleared persons in each agency 2 KISSI data are often supplemented and validated by independent assessments conducted by the NITTF 3 KISSI results are classified and will not be processed on this enclave

Indicators in development:

High Level Indicator Potential Target Areas

CE program data supporting Insider Threat Programs

Key Indicators – Continuous Evaluation / Availability and Sharing of Relevant Information

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Indicators in development: Develop mechanism to track CE metrics, Percentage of designated D/As meeting IOC Percentage of designated D/As meeting FOC, Percentage of overdue PR population screened using automated record checks


Develop mechanism to track CE metrics

TBD

Percentage of designated D/As meeting IOC

Percentage of designated D/As meeting FOC

Percentage of overdue PR population screened using automated record checks

Indicators in development: Percentage of local law enforcement records provided of number requested, Percentage of local law enforcement records provided of number requested, Percentage of local law enforcement records provided via automated means


Percentage of local law enforcement records provided of number requested

TBD

Percentage of local law enforcement records provided via automated means

TBD

Denial of Criminal History Record Information by State (FY13 data)

Law Enforcement Record Search Volumes by Method (OPM FY13 Data)

Method Total Percentage of Total Searches

Electronic Database (Nlets and Statewide) 977,434 34%

Mailed or Faxed Inquiry 642,227 22%

In-Person Contacts With Law Enforcement Agencies 1,021,377 36%

Court Checks in lieu of law checks 215,202 8%

Total 2,856,240 100%

[1] Nlets, which is owned by the States, is a 501 (c) (3) nonprofit organization that was created over 45 years ago by the principal law enforcement agencies of the States.

Contextual Indicators – Availability of Relevant Information

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Key Indicators- Federal Investigative Standards

36

Key Implementation Data

Indicator Source Baseline Target Frequency Latest data Trend

Percentage of agencies in compliance with Tier 1 IOC

Agencies 0% 100% Quarterly – Beginning FY15Q1

TBD NA


Agencies 0% 100% Quarterly – Beginning FY15Q1

TBD NA


Agencies 0%

100%

Quarterly

TBD NA


Agencies 0%

100%

Quarterly

TBD NA


Agencies 0% 100% Quarterly TBD NA

Percentage of agencies in compliance with Tier 1 FOC

Agencies 0%

100% Quarterly TBD NA

Key Indicators – Oversight and Quality of Background Investigations and Adjudications

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Indicators in development: Assess and establish means and measures for Adjudicative Quality, Percentage of agencies using the Investigative Quality Standards, Ratio of Quality to Non-Quality completed investigations, Percentage of targeted agencies assessed for oversight purposes

High Level Indicator Projected Initial Collection Date

Potential Target Areas

Percentage of agencies using the Investigative Quality Standards

TBD

Ratio of Quality to Non-Quality completed investigations

TBD

Percentage of targeted agencies assessed for oversight purposes

FY15 Q4

Key Indicators – Risk Management with Appropriate Position Designations and Associated Investigations

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Indicators in development: Establish mechanism to track position re-designation outcomes/results, Agency reports of position re-designation results, Percent reduction in total number of clearance holders, Percent reduction in overdue reinvestigations

High Level Indicator Projected Initial Collection Date

Potential Target Areas

Agency reports of position re-designation outcomes/results TBD

Percent reduction in total number of clearance holders

FY15 Q4

Percent reduction in overdue reinvestigations

FY15 Q4

Key Indicators – Security and Suitability Alignment and Reciprocity

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Indicators in development: Number of agencies fully implementing government wide credential standards/criteria, Percent of agencies in compliance with training standards


Number of agencies fully implementing government-wide credentialing standards/criteria

TBD

Percent of agencies in compliance with training standards

FY15 Q4

Insider Threat and Security Clearance Reform...Improve Risk Management with Appropriate Position...

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